NRC’s Project Aim: Off-target?

A handful of years ago, there was talk about nearly three dozen new reactors being ordered and built in the United States. During oversight hearings, Members of Congress queried the Members of the Nuclear Regulatory Commission on efforts underway and planned to ensure the agency would be ready to handle this anticipated flood of new reactor applications without impeding progress. Those efforts included creating the Office of New Reactors and hiring new staffers to review the applications and inspect the reactors under construction.

Receding Tide

The anticipated three dozen applications for new reactors morphed into four actual applications, two of which have since been cancelled. The tsunami of new reactor applications turned out to be a little ripple, at best.

The tide also turned for the existing fleet of reactors. Unfavorable economics led to the closures of several reactors and the announced closures of several other reactors in the near future.

The majority of the NRC’s annual budget is funded through fees collected from its licensees. For example, in fiscal year 2017 the owner of an operating reactor paid $4,308,000 for the NRC’s basic oversight efforts. For extra NRC attention (such as supplemental inspections when reactor performance dropped below par and for reviews of license renewal applications), the NRC charged $263 per hour.

Still, the lack of upsizing from new reactors and abundance of downsizing from existing reactors meant that NRC would have fewer licensees from whom to collect funds.

Enter Project Aim

The NRC launched Project AIM in June 2014 with the intention of “right-sizing” the agency while retaining the skill sets necessary to perform its vital mission. Project Aim identified 150 items that could be eliminated or performed more cost-effectively. Collectively, these measures were estimated to save over $40 million.

Item 59 was among the highest cost-saving measures identified by Project Aim. It terminated research activities on risk assessments of fire hazards for an estimated savings of $935,000. The NRC adopted risk-informed fire protection regulations in 2004 to complement the fire protection regulations adopted by the NRC in 1980 in response to the disastrous fire at the Browns Ferry Nuclear Plant in Alabama. The fire research supported risk assessment improvements to better manage the fire hazards—or would have done so had it not been stopped.

Item 61 was also a high dollar cost-saving measure. It eliminated the development of new methods, models and tools needed to incorporate digital instrumentation and control (I&C) systems into probabilistic risk assessments (PRAs) with an estimated savings of $735,000. Nuclear power reactors were originally equipped with analog I&C systems (which significantly lessened the impact of the Y2K rollover problem). As analog I&C systems become more obsolete, plant owners are replacing them with new-fangled digital I&C systems. Digital I&C systems fail in different ways and at different rates than analog I&C systems and the research was intended to enable the PRAs to better model the emerging reality.

Item 62 eliminated development of methods, models, tools, and data needed to evaluate the transport of radioactive materials released during severe accidents into aquatic environments. For example, the 2011 severe accident at Fukushima involved radioactive releases to the Pacific Ocean via means not clearly understood. This cost-saving measure seems to preserve that secret.

The need to reduce costs is genuine. Where oh where could savings of $935,000 come if not from killing the fire research efforts? Perhaps the Office of Management and Budget (OMB) has the answer. On May 11, 2012, OMB issued Memorandum M-12-12 that capped the amount federal agencies spent on conferences at $500,000. This OMB action pre-dated Project Aim, but seems consistent with the project’s fiscal responsibility objectives.

But the NRC opts not to abide by the OMB directive. Instead, the NRC Chairman signs a waiver allowing the NRC to spend far more than the OMB limit on its annual Regulatory Information Conferences (RICs). How much does the RIC cost? In 2017, the RIC cost the NRC $932,315.39—nearly double the OMB limit and almost exactly equal to the amount fire research would have cost.

987 persons outside the NRC attended the RIC in 2017. So, the NRC spent roughly $944.60 per outsider at the RIC last year. But don’t fixate on that amount. Whether the NRC had spent $1,000,000 per person or $1 per person, the RIC did not make a single American safer or more secure. (It also did not make married Americans safer or more secure, either.)

Eliminating the RIC would save the NRC nearly a million dollars each year. That savings could fund the fire research this year, which really does make single and married Americans safer. And next year savings could fund the development of digital I&C risk assessment methods to better manage the deployment of these systems throughout the nuclear fleet. And the savings the following year could fund research into transport of radioactive materials during severe accidents.

If the cliché “knowledge is power” holds any weight, then stopping fire research, development of digital I&C risk assessment methods, and many other activities leaves the NRC powerless to properly manage the associated risks.

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